PRIVACY POLICY

Makeeva.Pro online platform

Version dated 28 October 2026

This Privacy Policy (the "Policy") describes how the Makeeva.Pro online platform (the "Platform", the "Service") processes users' personal data.

By using the Platform, you confirm that you have read this Policy and agree to its terms. If you do not agree with the Policy, you must stop using the Platform.

1. General provisions

1.1. This Policy applies to the processing of personal data of Users of the Platform, including:

• users who register an account and get access to the Video section and other sections of the Platform;

• users who choose to link their Platform account to their Telegram nickname.

1.2. For participation in certain paid programmes of the Platform, including the "Master Group" section, additional data processing terms apply as set out in this Policy, the relevant offer, the programme rules and/or the documents of the payment service.

1.3. This Policy has been drawn up taking into account the requirements of applicable personal data protection law, including:

• the law of the Republic of Korea on the protection of personal information;

• Russian Federal Law No. 152-FZ "On Personal Data" — to the extent applicable to Russian users;

• other mandatory provisions of the law of the User's country of residence, where they must be applied.

2. Controller and contact details

2.1. The controller of personal data within the Platform is the Administration of the Makeeva.Pro Platform (the "Administration").

2.2. For the purposes of Russian Federal Law No. 152-FZ "On Personal Data", the Administration acts as the personal data operator for Russian Users.

2.3. Contact address for personal data questions: Email: info@makeeva.pro Recommended subject line: "Personal data".

2.4. Further details about the Administration (legal entity, country of registration, address) are given in section 16 of this Policy.

3. Who this Policy applies to

3.1. This Policy applies to all Users who:

• visit the Platform,

• register an account,

• get access to the Video section and other sections of the Platform,

• optionally link their Platform account to a Telegram nickname,

• contact support.

3.2. This Policy does not govern data processing on third-party services (YouTube, RuTube, Telegram, etc.), even if the user follows links to them from the Platform or uses embedded elements. The owners of such services are responsible for data processing on them.

4. Categories of data we process

Under this Policy we process the minimum necessary amount of data.

4.1. Data you provide yourself

• Email address — to register an account, sign in and contact you.

• Name / nickname — if you enter it in your profile (optional).

• Telegram nickname — only if you link your account to Telegram on your own initiative and with your consent.

• Correspondence with support — any information you voluntarily send us by email or via the feedback form.

4.2. Technical data (logs and analytics)

We may automatically receive:

• IP address, date and time of sign-in, information about the device and browser used;

• data about actions on the Platform (page/video views, clicks, navigation within the service);

• cookies and similar identifiers (for example, to maintain the session, for authorisation, fraud protection and basic statistics).

4.3. What we intentionally do not collect

4.3.1. Under this Policy, the Administration intentionally does not collect:

• data on health status, diagnoses or therapy;

• information on nationality, religious or political views;

• data on criminal records, trade union membership, party affiliation, etc.

4.3.2. If you share such information in correspondence or comments on your own initiative, you do so voluntarily. The Administration does not request such data and asks you not to send it unless necessary.

4.3.3. We do not request or collect bank card data or other payment details when you use the Video section and basic functionality. The processing of payment data when participating in paid programmes is governed by separate documents.

5. Purposes of personal data processing

We process personal data only to the extent necessary for the following purposes:

5.1. Registering and maintaining an account

• creating and administering the personal account;

• providing access to the Video section and other sections of the Platform.

5.2. Operating the Service

• keeping the Platform running;

• authorisation and maintaining the session;

• protection against unauthorised access and abuse.

5.3. Communicating with the User

• sending service messages (registration confirmation, password change notifications, etc.);

• responding to support requests.

5.4. Linking to Telegram (with your consent)

• linking your Telegram nickname/ID to your Platform account;

• identifying you in closed chats/channels associated with the Platform.

5.5. Analytics and service development

• analysing aggregated statistics on the use of the Platform;

• improving the structure, interface and content.

5.6. Compliance with legal requirements

• fulfilling the Administration's obligations under applicable law;

• responding to lawful requests from public authorities, if any are received.

5.7. Marketing emails (only with separate consent)

• sending news and information about new programmes and materials of the Platform if you are subscribed. You can always unsubscribe via the link in the email or by writing to us.

6. Legal grounds for processing

Depending on the specific situation, we rely on the following legal grounds:

6.1. Performance of a contract (the offer / user agreement) — where processing is necessary to register an account and provide access to the Platform and its functionality.

6.2. The User's consent — when you:

• register on the Platform and accept the Agreement and the Policy;

• link your account to a Telegram nickname;

• subscribe to marketing emails.

6.3. The Administration's legitimate interests — ensuring the security of the Platform, preventing abuse, basic analytics and statistics.

6.4. Compliance with legal requirements — where processing is required to comply with the Administration's legal obligations.

You may withdraw consent you have given (for example, to the Telegram link or to emails). Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

7. Cookies and similar technologies

7.1. The Platform may use:

• technical cookies — for authorisation, maintaining the session and saving settings;

• analytics cookies — to collect anonymised statistics on the use of the Platform;

• browser local storage and similar technologies.

7.2. You can manage the use of cookies in your browser settings (block or delete them). If technical cookies are disabled completely, some functions of the Platform may be impaired or unavailable.

8. Where data are stored and cross-border transfers

8.1. Technical storage of data: the Platform's infrastructure (servers, database, file storage) and backups are hosted by hosting providers in the Republic of Korea and the Russian Federation.

8.2. Access from abroad

• The Administration and authorised persons may have remote access to the data from other countries, including the Republic of Korea.

• Such remote access is legally considered a cross-border transfer of personal data.

8.3. Transfers to other countries

• In certain cases, data may be processed and stored on the servers of contractors (email service, analytics, etc.), which may be located in different jurisdictions.

• By accepting this Policy, you consent to the cross-border transfer of your personal data to the countries where the Administration and its contractors are located, to the extent necessary for the operation of the Platform and the performance of obligations to you.

8.4. The Administration takes reasonable measures to ensure an adequate level of protection of personal data during cross-border transfers in accordance with applicable law.

9. Who we share data with

9.1. The Administration does not sell personal data to third parties and does not disclose it other than in the cases set out in this Policy or required by law.

9.2. Data may be shared with:

9.2.1. Technical contractors and service providers who help us to:

• host and maintain the Platform (hosting providers, data centres);

• send emails and service notifications;

• collect and analyse visit statistics;

• ensure security and protection against abuse.

9.2.2. Persons operating the Telegram channels/chats associated with the Platform — to the extent necessary to identify your Telegram nickname as a participant (when the account is linked).

9.2.3. Public authorities — where such disclosure is expressly required by law or is necessary to protect the rights and legitimate interests of the Administration, Users or third parties.

9.2.4. Successors — in the event of a reorganisation, sale of the business or transfer of rights to the Platform, provided that they maintain data protection obligations at a level no lower than that established by this Policy.

9.2.5. Paddle.com Market Limited (United Kingdom) — the online reseller and Merchant of Record for payments in euros and US dollars. When an order is placed, Paddle independently, as a separate controller, receives and processes the email address, country and postcode, payment data and order details; the Administration receives from Paddle the information needed to provide access and support (email, subscription status, amount, currency and date of payment). Paddle's Privacy Policy: paddle.com/legal/privacy.

9.3. In all cases, we aim to share the minimum necessary amount of data.

10. Personal data retention periods

10.1. Personal data are stored:

• for as long as you have an active account on the Platform;

• thereafter — for the period necessary for:

  • protecting the rights and legitimate interests of the Administration in possible disputes,

  • complying with legal requirements (for example, accounting and tax records),

  • backups and access logs.

10.2. As a general rule, after an account is deleted and in the absence of other lawful grounds for retention, data may be kept for up to 3 (three) years, unless a longer period is required by law.

10.3. When the retention periods expire, the data are deleted or anonymised.

11. Users' rights

11.1. To the extent provided by applicable law, you may contact us with a request to:

• find out whether your personal data are processed and which data;

• correct (clarify, update) inaccurate or outdated data;

• delete or restrict the processing of personal data where there are lawful grounds for doing so (for example, the data are no longer needed for the purposes of processing, or processing is carried out without a proper basis).

11.2. To exercise your rights, you can send a request to the email address given in section 2 and section 16 of this Policy. In the request, please state the email address the account is registered to and describe what exactly you want: to find out, correct or delete.

11.3. We will consider your request within the time limits set by applicable law and will either:

• fulfil it (for example, update or delete the data),

• or explain why the request cannot be fully fulfilled in the specific situation (for example, if some of the data must be retained by law or are necessary to protect our rights in possible disputes).

12. Data protection measures

12.1. The Administration applies technical and organisational measures to protect personal data against:

• unauthorised access;

• accidental loss, destruction or alteration;

• unlawful disclosure.

12.2. Among other things, the following may be used:

• restricting access to data on a "need to know" basis;

• authorisation systems and action logging;

• protection of servers and software infrastructure.

12.3. At the same time, the User understands and agrees that:

• no method of transmitting data over the Internet or of electronic storage can be absolutely secure;

• the Administration cannot guarantee complete protection against all possible cyber threats;

• security also largely depends on the User's own actions (using strong passwords, protecting the device and mailbox, etc.).

13. Children and special categories of users

13.1. The Platform is intended for Users over 18 years of age.

13.2. The Administration does not knowingly collect personal data of children under 18 without the consent of their legal representatives. If you believe that a child has provided us with data without the consent of their parents/guardians, please contact us — we will take steps to delete such information in the absence of lawful grounds for retaining it.

13.3. The Platform is not intended for the targeted collection of special categories of data (health, diagnoses, religion, political views, etc.), and the Administration asks you not to send such data unless absolutely necessary.

14. Processing of data of Master Group participants

14.1. If the User participates in the Master Group, the Administration may additionally process the data needed to provide access and run the group: the account email, nickname, Telegram nickname when Telegram spaces are used, subscription status, amount, currency, date and time of payment, as well as technical information received via the payment service.

14.2. Access to the Master Group is paid for through external payment services (for payments in euros and US dollars — Paddle.com, see clause 9.2.5; for payments in roubles — the payment services specified in the offer) and/or payment providers associated with them. The Administration does not receive or store the full bank card number, its expiry date, the CVV/CVC code or other full payment details of the User.

14.3. Within the Master Group, the User may voluntarily post questions, comments, messages, practical assignments, self-work exercises and other written materials on the Makeeva.Pro Platform and/or in associated closed Telegram spaces.

14.4. Such materials may be used by the Administration to organise the work of the Master Group, prepare breakdowns and feedback, improve the methodology, and develop the project's materials and technical tools, including with the use of commercial software and AI tools.

14.5. For these purposes, the Administration uses the User's written materials and, where necessary, their nickname, in order to understand which materials belong to the same participant.

14.6. The Master Group is a closed space, but not a space of guaranteed confidentiality. Materials posted in shared chats, comments or discussions may be visible to other participants. If the User does not want to disclose personal details, they should change names, circumstances and other identifying features themselves before posting.

14.7. The Administration does not sell participants' personal stories as a database to third parties and does not publish the User's personal materials publicly without separate consent.

15. Changes to the Policy

15.1. The Administration may update this Policy from time to time.

15.2. The current version of the Policy is always available on the Platform. The date of the last update is given at the beginning of the document.

15.3. In the event of material changes, the Administration may additionally notify Users (for example, via the Platform interface or by email, where technically possible).

15.4. By continuing to use the Platform after the changes take effect, you confirm that you have read the new version of the Policy and agree to it.

16. Administration of the Platform and details

16.1. The Administration of the Makeeva.Pro Platform is Mironi.

16.2. Legal information about the Administration:

• full name: Mironi Co., Ltd.

• country of registration: Republic of Korea

• registered address: M38, B105, 196 World Cup-ro, Mapo-gu, Seoul, 03938, Republic of Korea

• contact email: info@makeeva.pro

16.3. For any questions related to personal data and this Policy, you can contact us at the email address given in clause 16.2.